Will the Stellantis judgment bring clarity across the EU on the VAT treatment of transfer pricing adjustments?

Will the Stellantis judgment bring clarity across the EU on the VAT treatment of transfer pricing adjustments?

The Court of Justice of the European Union has, for the first time, ruled in a case directly addressing the VAT implications of transfer pricing adjustments (Case C-603/24 Stellantis Portugal). This is a highly significant and controversial issue across the EU due to the absence of a harmonised approach among Member States.

Disposal of an organised part of an enterprise – what does it involve, what are the tax risks and how can they be secured?

Disposal of an organised part of an enterprise – what does it involve, what are the tax risks and how can they be secured?

Organised part of an enterprise Tax regulations define an organised part of an enterprise [hereinafter: OPE] as a set of assets – tangible and intangible, including liabilities – organisationally and financially separated within an existing enterprise, intended to perform specific business tasks, which could also constitute an independent enterprise performing these tasks on its own.…

CJEU: board member has the right to defend himself - another important judgment on joint and several liability

CJEU: board member has the right to defend himself – another important judgment on joint and several liability

On 30 April 2025, the Court of Justice of the European Union (CJEU) delivered another important judgment in Case C-278/24 (Genzyński) concerning the compatibility with EU law of the Polish rules on the joint and several liability of board members for company tax arrears. The CJEU ruled that the current regulations – while permissible under…